Forms N-PORT and N-CEN

Overview of the regulation

On January 17, 2017 the Investment Company Reporting Modernization rule, proposed in May, 2015 by the Securities and Exchange Commission (SEC) became effective. The rule  “adopted new rules and forms to modernize the reporting and disclosure of information by registered investment companies.”   The SEC adopted new Forms N-PORT and N-CEN to modernise the current reporting and disclosure requirements for mutual funds, Exchange Traded Funds (ETFs) and other registered investment companies (RICs). Both rules are seeking to modernise and enhance the quality of data reported by mutual funds, ETFs and RICs. The two forms are coming in to replace existing forms, the existing N-Q to be replaced by N-PORT and  the existing  N-SAR with  N-CEN.

Timeline

  • 1 June 2018 - N-PORT Larger RICs (NAV >= $1 billion)
  • 1 June 2018 - N-CEN All RICs
  • 1 June 2019 - N-PORT Smaller RICs (NAV < $1 billion)

Who is affected by this regulation?

  • N-PORT impacts Registered Investment Companies (RICs) and exchange-traded funds (“ETFs”) organized as unit investment trusts (“UITs”), other than  money market funds and small business investment companies (SBICs).
  • N-CEN impacts RICs including money market funds.

Key points for consideration / what funds need to be reported?

Form N-PORT

Form N-PORT is a portfolio reporting form requiring registered funds to provide portfolio-wide and position-level holdings on a monthly basis reportable to the SEC.

The form will require data on the funds investments, including:

  1. Data related to the pricing of portfolio securities
  2. Information regarding repurchase agreements, securities lending activities, and counterparty exposures
  3. Terms of derivatives contracts
  4. Discrete portfolio level and position level risk measures to better understand fund exposure to changes in market conditions

Form N-CEN

Form N-CEN will require applicable funds to annually report census-type information to the SEC.

Census type information will include background and classification of fund as well as information about the Funds directors and Chief Compliance Officer.

The form will also require data on:

  1. Investment in controlled foreign corporations
  2. Securities lending
  3. Increased information on ETFs

Note: both forms will be required to be reported in a Structured XML format.

When is the deadline for reporting?

  • Form N-PORT must be reported monthly (within 30 days after the end of each month)
  • Form N-CEN must be reported yearly (within 75 days after the end of the fiscal year)

How can UnaVista Assist?

  • Data aggregation – information required by form N-PORT & N-CEN will require data aggregation, UnaVista can assist in data aggregation and calculations required to report.
  • UnaVista rules engine can assist in gathering information from multiple source systems and normalising, enriching and transforming the data required to be reported.
  • Automated XML report generation and workflow and exception management helping clients validate their data, manage operational risk and stay compliant.
  • UnaVista regulatory hub combines all your regulatory reporting requirements within one platform.

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